SUBJECT: MAXIMUM RESERVE VALUATION AND MAXIMUM LIFE POLICY NONFORFEITURE INTEREST RATES UNDER SECTIONS 4217, 4218, AND 4221(k) OF THE NEW YORK INSURANCE LAWS, AS AMNED IN 1982, 1983, 1985, 1986, 1987, 1988, AND 1990

Attached hereto is an outline, providing maximum reserve valuation and maximum life policy nonforfeiture
interest rates for new issues, new purchases or changes in fund (as defined) for years 1982 through
1991 (and other years where shown), under Sections 4217, 4218 and 4221(k) of the New York Insurance
Laws, as amended in 1982, 1983, 1985, 1986, 1987, 1988, and 1990.

This Circular Letter is for informational purposes, as an aid in complying with the law.

Should any person have any question or comment, in regard to this matter, please contact Mr. Robert
J. Callahan, Chief of the Actuarial Valuation Bureau (518-474-7929) or Mr. Paul H. Schoener (518-474-7929)
or Mr. Richard C. Dielensnyder (518-474-6605).

Unless you inform Mr. Dielensnyder to the contrary, future editions of this letter will only be sent
to the Chief Actuary, or absent such, to the Chief Financial Officer.

Very truly yours,

[SIGNATURE]

Salvatore R. Curiale

Superintendent of. Insurance

CIRCULAR LETTER No. 15 (1991)

MAXIMUM VALUATION AND NONFORFEITURE INTEREST RATES UNDER SECTIONS 4217, 4218 and 4221(k) OF THE NEW YORK INSURANCE LAWS

The maximum valuation and nonforfeiture interest rates, prescribed by Sections 4217 and 4221(k) of
the New York Insurance Laws for future years, will vary from year to year depending on Moody's corporate
bond yield averages.

The maximum valuation interest rates for issues, purchases and changes-in-fund of years 1982 through
1991 (and other years where shown) are outlined below. The maximum valuation and nonforfeiture interest
rates for Ordinary Life Insurance are shown in A on page 2, except for Single Premium Life Insurance
(of the kind referred to in Section 4217(c)(4)(B)(vi) as amended by Chapter 302 of the laws of 1987)
the maximum valuation interest rates for which are shown in B on page 3.

This Circular Letter is for informational purposes, as an aid in complying with the law.

A. ORDINARY LIFE INSURANCE (Except as covered in B on page 3)

***Maximum

Maximum

*Issue

Reserve Valuation

Nonforfeiture

Year

**Guarantee Duration

Interest Rate

Interest Rate

# 1980

1958

CSO

CSO

1979-81

See Prior Circular Letters

1982-83

1984

10 Years or Less

7.25%

9.00%

5.50%

More than 10 Years, up to 20

6.75

8.50

5.50

More than 20 Years

6.00

7.50

5.50

1985

10 Years or Less

7.25%

9.00%

5.50%

More than 10 Years, up to 20

6.75

8.50

5.50

More than 20 Years

6.00

7.50

5.50

1986

10 Years or Less

7.25%

9.00%

5.50%

More than 10 Years; up to 20

6.75

8.50

5.50

More than 20 Years

6.00

7.50

5.50

1987

10 Years or less

6.50%

## 8.25%

5.50%

More than 10 Years, up to 20

6.00

## 7.50

5.50

More than 20 Years

5.50

## 7.00

5.50

1988

10 Years or less

6.00%

## 7.50%

5.50%

More than 10 years, up to 20

6.00

## 7.50

5.50

More than 20 years

5.50

## 7.00

5.50

1989

10 Years or less

6.00%

7.50%

###

More than 10 years, up to 20

6.00

7.50

###

More than 20 years

5.50

7.00

###

1990

10 Years or less

6.00%

7.50%

###

More than 10 years, up to 20

6.00

7.50

###

More than 20 years

5.50

7.00

###

1991

10 Years or less

6.00%

7.50%

###

More than 10 years, up to 20

6.00

7.50

###

More than 20 years

5.50

7.00

###

1992

10 Years or less

6.00%

7.50%

#

More than 10 years, up to 20

6.00

7.50

#

More than 20 years

5.50

7.00

#

*See the paragraph at the top of page 11.

**The guarantee duration is the maximum number of

years the life insurance can remain in

force on a basis guaranteed in the policy.

***The maximum reserve valuation interest rate

will be the lesser of the rate as determined

from the above table and the rate actually used

in determining cash values. This applies

to basic reserves under Section 4217, not to the

minimum reserve test under Sect. 4218.

# Applicable on or after the operative date elected

under Section 4221(k)(12). (See the

top paragraph on page 10). These rates do not

apply to policies issued pursuant to

Section 4221(n-1).

# # In accordance with Section 4221(k)(9)(8)(1)

of the New York Insurance Laws, the

nonforfeiture interest rate used for a particular

issue year may not exceed the higher

of the applicable maximum nonforfeiture interest rate

for such particular issue year and

that for the immediately preceeding issue year

(e.g. 1987 issues may use the rate for

1986, 1988 issues may use the rate for 1987).

### See the paragraph at the top of page 11.

As of January 1, 1989,

the 1980 CSO rate must used for all new business.

B. Single Premium Life Insurance of the kind referred to in Section 4217(c)(4)(B)(vi) of the New York
Insurance Laws (as amended by Chapter 302 of the laws of 1987). #

## Maximum

Year

**Guaranteed Duration

Reserve Valuation

J*4*Interest Rate

Issue Year

Change-In-Fund

Basis

Basis

Without

With

Without

With

AO&M

AO&M

AO&M

AO&M

***

****

***

****

1982, 1983

See Prior Circular Letters

1984

10 years or less

7.50%

8.50%

7.75%

9.25%

More than 10 yrs, up to 20

7.00

7.00

7.50

8.50

More than 20 years

6.25

6.25

6.75

7.50

1985

10 years or less

7.50%

8.50

7.75%

9.00%

More than 10 yrs, up to 20

7.00

7.00

7.50

8.50

More than 20 years

6.25

6.25

6.50

7.50

1986

10 years or less

6.75%

7.25%

7.00%

7.75%

More than 10 yrs, up to 20

6.50

6.50

6.75

7.25

More than 20 years

5.75

5.75

6.00

6.50

1987

10 years or less

6.50%

6.50%

6.75%

6.75%

More than 10 yrs, up to 20

6.00

6.00

6.50

6.50

More than 20 years

5.50

5.50

5.75

6.00

1988

10 years or less

6.75%

7.00%

7.00%

7.50%

More than 10 yrs, up to 20

6.25

6.25

6.75

7.00

More than 20 years

5.75

5.75

6.00

6.25

1999

10 years or less

6.50%

7.00%

7.00%

7.25%

More than 10 yrs, up to 20

6.25

6.25

6.50

7.00

More than 20 years

5.50

5.50

6.00

6.25

1990

10 years or less

6.50%

6.50%

6.75%

7.00%

More than 10 yrs, up to 20

6.25

6.25

6.50

6.50

More than 20 years

5.50

5.50

5.75

6.00

1991

10 years or less

6.50%

6.75%

6.75%

7.00%

More than 10 yrs, up to 20

6.25

6.25

6.50

6.75

More than 20 years

5.50

5.50

5.75

6.00

*See the paragraph at the top of page 11.

**The guarantee duration is the number of years for which

interest rates provided in, or declared pursuant to, a single

premium life insurance policy of the kind referred to in

Section 4217(c)(4)(B)(vi) are guaranteed to exceed the greater

of (1) 6% and (2) the calendar year statutory valuation interest

rate for life insurance policies (other than such single

premium policy) with guarantee durations in excess of 20 years.

***Without an acceptable actuarial opinion and memorandum

(using life insurance formula). Additional restrictions may

apply by Regulation.

****May be used only with an acceptable actuarial opinion and

apply memorandum (using annuity formula).

# Said Chapter 302 amendment became effective, on a mandatory

basis, on January 1, 1989. Any company could have filed a written

notice of prior election.

See paragraph on reserves, for these special single premium life insurance policies on page 11. Also
see paragraph, at bottom of page 4.

B. Single Premium Life Insurance of the kind referred to in Section 4217(c)(4)(B)(vi) of the New York
Insurance Laws (as amended by Chapter 302 of the laws, of 1987).#

**Guarantee Duration Interest Rate

# # Maximum Reserve Valuation

Issue Year Basis

Change-In-Fund

Basis

Without

With

Without

With

AO&M

AO&M

AO&M

AO&M

***

****

***

****

1982, 1983

See Prior Circular Letters

1984

10 years or less.

7.50%

8.50%

7.75%

9.25%

More than 10 yrs, up to 20

7.00

7.50

7.50

8.50

More than 20 years

6.25

6.25

6.75

7.50

1985

10 years or less

7.50%

8.50%

7.75%

9.00%

More than 10 yrs, up to 20

7.00

7.00

7.50

8.50

More than 20 years

6.25

6.25

6.50

7.50

1986

10 years or less

6.75%

7.25%

7.00%

7.75%

More than 10 yrs, up to 20

6.50

6.50

6.75

7.25

More than 20 years

5.75

5.75

6.00

6.50

1987

10 years or less

6.50%

6.50%

6.75%

6.75%

More than 10 yrs, up to 20

6.00

6.00

6.50

6.50

More than 20 years

5.50

5.50

5.75

6.00

1988

10 years or less

6.75%

7.00%

7.00%

7.52%

More than 10 yrs, up to 20

6.25

6.25

6.50

7.00

More than 20 years

5.75

5.75

6.00

6.25

1989

10 years or less

6.50%

7.00%

7.00%

7.25%

More than 10 yrs, up to 20

6.25

6.25

6.50

7.00

More than 20 years

5.50

5.50

6:00

6.25

1990

10 years or less

6.50%

6.50%

6.75%

7.00%

More than 10 yrs, up to 20

6.25

6.25

6.50

6.50

More than 20 years

5.50

5.50

5.75

6.00

1991

10 years or less

6.50%

6.75%

6.75%

7.00%

More than 10 yrs, up to 20

6.25

6.25

6.50

6.75

More than 20 years

5.50

5.50

5.75

6.00

*See the paragraph at the top of page 11.

**The guarantee duration is the number of

years for which interest rates provided in, or declared

pursuant to, a single premium life insurance policy of the

kind referred to in Section 4217(c)(4)(B)(vi) are guaranteed

to exceed the greater of (1) 6% and (2) the calendar year

statutory valuation interest rate for life insurance policies

(other than such single premium policy) with guarantee

durations in excess of 20 years.

***Without an acceptable actuarial opinion and memorandum

(using life insurance formula). Additional restrictions

may apply by Regulation.

****May be used only with an acceptable actuarial opinion

and memorandum (using annuity formula).

# Said Chapter 302 amendment became effective., on a

mandatory basis, on January 1, 1989. Any company could have filed

a written notice of prior election.

See paragraph on reserves for these special single premium life insurance policies on page 11. Also
see paragraph at bottom of page 4.

guarantee duration, for other annuities and guaranteed interest contracts without cash settlement
options, is the number of years from the date of issue or date of purchase to the date annuity benefits
are scheduled to commence.

G. Other Annuities and Guaranteed. Interest Contracts, with cash settlement options and with interest
rate guarantees on future considerations, valued on the "Change in Fund" basis.

Maximum Reserve Valuation

Interest Rate

Without Acceptable

Acturial Opinion

and Memorandum #

(Using Life Insurance

Formula)

Change

in Fund

*Plan Type

During

Year

Guarantee Duration##

A

B

C

1982, 1983

See Prior Circular Letters

1984

5 years or less

10.75%

10.00%.

7.50%

More than 5 yrs, up to 10

10.25

10.00

7.50

More than 10 yrs, up to 20

9.50

9.00

7.00

More than 20 years

7.75

7.75

6.25

1985

5 years or less

10.50%

9.75%

7.50

More than 5 yrs, up to 10

10.25

9.75

7.50

More than 10 yrs, up to 20

9.50

9.00

7.00

More than 20 years$

7.75

7.75

6.25

1986

5 years or less

9.50%

8.75%

6.75%

More than 5 yrs, up to 10

9.25

8.75

6.75

More than 10 yrs, up to 20

8.50

8.25

6.50

More than 20 years

7.00

7.00

5.75

1987

5 years or less

9.00%

8.25%

6.50%

More than 5 yrs, up to 10

8.50

8.25

6.50

More than 10 yrs, up to 20

8.00

7.75

6.00

More than 20 years

6.75

6.75

5.50

1988

5 years or less

9,25%

8.75%

6.75%

More than 5 yrs, up to 10

9.00

8.75

6.75

More than 10 yrs, up to 20

8.25

8.00

6.25

More than 20 years

7.00

7.00

5.75

1989

5 years or less

9.25%

8.50%

6.50%

More than 5 yrs, up to 10

9.00

8.50

6.50

More than 10 yrs, up to 20

8.25

8.00

6.25

More than 20 years

7.00

7.00

5.50

1990

5 years or less

9.00%

8.25%

6.50%

More than 5 yrs, up to 10

8.75

8.25

6.50

More than 10 yrs, up to 20

8.00

7.75

6.25

More than 20 years

6.75

5.75

5.50

1991

5 years or less

9.00%

8.25%

6.50%

More than 5 yrs, up to 10

8.75

8.25

6.50

More than 10 yrs, up to 20

8.00

7.75

6.25

More than 20 years

6.75

6.75

5.50

# See requirements for actuarial opinion and memorandum in

footnote on page 4.

Additional restrictions apply, under Regulation 126, where

an acceptable actuarial opinion and memorandum have not been filed.

## See definition of guarantee duration for Categories

D, E, G and H on page. 10.

* See descriptions of plan types on page 10.

Maximum Reserve Valuation

Interest Rate

With Acceptable

Acturial Opinion

and Memorandum #

(Using Annuity Formula)

Change

in Fund

*Plan Type

During

Year

Guarantee Duration##

A

B

C

1982, 1983

See Prior Circular Letters

1984

5 years or less

12.75%

11.75%

8.50%

More than 5 yrs, up to 10

12.25

11.75

8.50

More than 10 yrs, up to 20

11.25

10.75

8.00

More than 20 years

9.25

9.25

7.00

1985

5 years or less

12.50%

11.50%

8.50%

More than 5 yrs, up to 10

12.00

11.50

8.50

More than 10 yrs, up to 20

11.00

10.50

8.00

More than 20 years

9.00

9.00

7.00

1986

5 years or less

10.25%

9.50%

7.25%

More than 5 yrs, up to 10

10.00

9.50

7.25

More than 10 yrs, up to 20

9.25

8.75

6.75

More than 20 years

7.75

7.75

6.00

1987

5 years or less

9.00%

8.50%

6.50%

More than 5 yrs, up to 10

8.75

8.50

6.50

More than 10 yrs, up to 20

8.00

7.75

6.25

More than 20 years

6.75

6.75

5.50

1988

5 years or less

10.00%

9.25%

7.00%

More than 5 yrs, up to 10

9.50

9.25

7.00

More than 10 yrs, up to 20

8.75

8.50

6.75

More than 20 years

7.50

7.50

6.00

1989

5 years or less

9.75%

9.00%

7.00%

More than 5 yrs, up to 10

9.50

9.00

7.00

More than 10 yrs, up to 20

8.75.

8.25

6.50

More than 20 years

7.25

7.25

5.75

1990

5 years or less

9.25%

8.50%

6.50%

More than 5 yrs, up to 10

8.75

8.50

6.50

More than 10 yrs, up to 20

8.25

8.00

6.25

More than 20 years

7.00

7.00

5.50

1991

5 years or less

9.25%

8.75%

6.75%

More than 5 yrs, up to 10

9.00

8.75

6.75

More than 10 yrs, up to 20

8.25

8.00

6.25

More than 20 years

7.00

7.00

5.75

Other Annuities and guaranteed interest contracts, with cash settlement options but without interest
rate guarantees on future considerations, valued on the "Change in Fund" basis.

Maximum Reserve

Valuation Interest Rate

Without Acceptable

Actuarial Opinion

and Memorandum#

Change

(Using Life

Insurance Formula)

in fund

*Plan Type

During

Year

Guarantee Duration##

A

B

C

1982, 1983

See Prior Circular Letters

1984

5 years or less

11.00%

10.25%

7.75%

More than 5 yrs, up to 10

10.75

10.25

7.75

More than 10 yrs, up to 20

10.00

9.50

7.50

More than 20 years

8.25

8.25

6.75

1985

5 years or less

11.00%

10.25%

7.75%

More than 5 yrs, up to 10

10.50

10.25

7.75

More than 10 yrs,up to 20

9.75

9.50

7.50

More than 20 years

8.25

8.25

6.50

1986

5 years or less

9.75%

9.25%

7.00%

More than 5 yrs, up to 10

9.50

9.25

7.00

More than 10 yrs, up to 20

8.75

8.50

6.75

More than 20 years

7.50

7.50

6.00

1987

5 years or less

9.25%

8.50%

6.75%

More than 5 yrs, up to 10

9.00

8.50

6.75

More than 10 yrs, up to 20

8.25

8.00

6.50

More than 20 years

7.00

7.00

5.75

1988

5 years or less

9.75%

9.00%

7.00%

More than 5 yrs, up to 10

9.2.5

9.00

7.00

More than 10 yrs, up to 20

8.75

8.25

6.75

More than 20 years

7.25

7.25

6.00

1989

5 years or less

9.50%

9.00%

7.00%

More than 5 yrs, up to 10

9.25

9.00

7.0

More than 10 yrs, up to 20

8.50

8.25

6.50

More than 20 years

7.25

7.25

6.00

1990

5 years or less

9.25%

8.75%

6.75%

More than 5 yrs, up to 10

9.00

8.75

6.75

More than 10 yrs, up to 20

8.25

8.00

6.50

More than 20 years

7.00

7.00

5.75

1991

5 years or less

9.25%

8.75%

6.75%

More than 5 yrs, up to 10

9.00

8.75

6.75

More than 10 yrs, up to 20

8.25

8.00

6.50

More than 20 years

7.00

7.00

5.75

# See requirements for actuarial opinion and memorandum in

footnote on page 4.

Additional restrictions apply, under Regulation 126, where

an acceptable actuarial opinion and memorandum have not been

filed.

# # See definition of guarantee duration for Categories D, E,

G and H on page 10.

*See descriptions of plan types on page 10.

Maximum Reserve

Valuation Interest Rate

With Acceptable

Actuarial Opinion

and Memorandum#

Change

(Using Annuity

Formula)

in fund

*Plan Type

During

Year

Guarantee Duration##

A

B

C

1982, 1983

See Prior Circular Letters

1984

5 years or less

13.25%

12.25%

9.25%

More than 5 yrs, up to 10

12.75

12.25

9.25

More than 10 yrs, up to 20

11.75

11.25

8.50

More than 20 years

9.75

9.75

7.50

1985

5 years or less

13.00%

12.00%

9.00%

More than 5 yrs, up to 10

12.50

12.00

9.00

More than 10 yrs,up to 20

11.50

11.00

8.50

More than 20 years

9.50

9.50

7.50

1986

5 years or less

10.75%

10.00%

7.75%

More than 5 yrs, up to 10

10.25

10.00

7.75

More than 10 yrs, up to 20

9.50

9.25

7.25

More than 20 years

8.00

8.00

6.50

1987

5 years or less

9.50%

8.75%

6.75%

More than 5 yrs, up to 10

9.00

8.75

6.75

More than 10 yrs, up to 20

8.50

8.00

6.50

More than 20 years

7.25

7.25

6.00

1988

5 years or less

10.25%

9.50%

7.50%

More than 5 yrs, up to 10

10.00

9.50

7.50

More than 10 yrs, up to 20

9.25

8.75

7.00

More than 20 years

7.75

7.75

6.25

1989

5 years or less

10.00%

9.50%

7.25%

More than 5 yrs, up to 10

9.75

9.50

7.25

More than 10 yrs, up to 20

9.00

8.75

7.00

More than 20 years

7.50

7.50

6.25

1990

5 years or less

9.50%

8.75%

7.00%

More than 5 yrs, up to 10

9.25

8.75

7.00

More than 10 yrs, up to 20

8.50

8.25

6.50

More than 20 years

7.25

7.25

6.00

1991

5 years or less

9.75%

9.00%

7.00%

More than 5 yrs, up to 10

9.25

9.00

7.00

More than 10 yrs, up to 20

8.75

8.25

6.75

More than 20 years

7.25

7.25

6.00

Said Section 4221(k)(12) was amended by Chapter 81 of the Laws of 1983 to permit a company to elect
to comply with the new provisions of Section 4221 on a plan-by-plan basis, with the proviso that
the entire portfolio must be converted to the new provisions on or before January 1 of the third
calendar year following the calendar year of compliance for the first plan so converted, but not,
in any event, later than January 1, 1989.

Plan types, as used in the above tables, are defined as follows:

Plan Type A: The policyholder may withdraw funds only (1) with an adjustment to reflect changes in
interest rates or asset values since receipt of the funds by the insurance company, or (2) without
such adjustment but in installments over five years or more, or (3) as an immediate life annuity.

Plan Type B: The policyholder may not withdraw funds before the expiration of the interest rate guarantee
or, if withdrawals are permitted before the expiration of such guarantee, may withdraw funds only
(1) with an adjustment to reflect changes in interest rates or asset values since receipt of the
funds by the insurance company, or (2) without such adjustment but in installments over five years
or more. At the end of the interest rate guarantee, funds may be withdrawn without such adjustment
in a single sum or in installments over less than five years.

Plan Type C: The policyholder may withdraw funds before the expiration of the interest rate guarantee
in a single sum or installments over less than five years either (1) without adjustment to reflect
changes in interest rates or asset values since receipt of the funds by the insurance company, or
(2) subject only to a fixed surrender charge stipulated in the contract as a percentage of the fund.

(The most popular plan type, in the group annuity area, for current issues, is plan type B; while,
the most popular plan type, in the individual annuity area, for current issues, is plan type C.)

The guarantee duration, for other annuities and guaranteed interest contracts with cash settlement
options, generally is the number of years for which the contract guarantees interest rates in excess
of the calendar year statutory valuation interest rate for life insurance policies (covered in A
on page 2) with guarantee durations of more than twenty years (See D, E, G and H herein).

The guarantee duration, for other annuities and guaranteed interest contracts without cash settlement
options, is the number of years from the date of issue or date of purchase to the date annuity benefits
are scheduled to commence.

Other annuities and guaranteed interest contracts, without cash settlement Options, may be valued
only on an "Issue Year" basis.

For structured settlement annuities with lump-sum payments, see Section 95.12 of Regulation 126.

The maximum reserve valuation interest rates, for annuities and guaranteed interest contracts and
for single premium life insurance policies of the kind referred to in Section 4217(c)(4)(B)(vi),
are based on Moody's Corporate Bond Yield Averages for a one or three year period ending in June
of the year of issue, purchase or change in fund. Consequently, we are not able to compute rates
applicable to 1992 at this time.

The attached Appendix describes the method of calculating the maximum reserve valuation interest rates,
in accordance with the specifications of Section. 4217 of the New York Insurance Laws, as amended.

Section 4217, as amended by Chapter 749 of the Laws of 1983, permits the dynamic interest rates (under
the 1982 amendments) to be used for issues of January 1, 1982 and later, irrespective of a company's
election or. non-election under Section 4221 (k)(12). Thus, the new dynamic interest rates may be
used either with 1958 CSO issues of January 1, 1982 through December 31, 1988 or with 1980 CSO issues
of January 1, 1982 and later, for valuation purposes.

The reserve for a Single Premium Life Insurance policy, of the kind referred to in Section 4217(c)(4)(B)(vi)
of the New York Insurance Laws (as amended by Chapter 302 of the laws of 1987), must not be less
than its cash value. Section 95.14 of Regulation 126 limits the applicable duration of maximum reserve
valuation interest rates specified in B on page 3.

APPENDIX

To Circular Letter Number 15 (1991)

The maximum reserve valuation interest rates are based on reference interest rates, which are averages
of corporate bond earnings published by Moody's Investors Service, Inc., and weighting factors prescribed
by Section 4217.

The weighting factors do not vary from year to year. None of the weighting factors given in Table
1 below will change unless Section 4217 is revised by. new legislation. The following formulas are
used to compute the maximum reserve valuation interest rates:

The third term of Formula 1 is dropped whenever the reference interest rate falls below 9.00%. The
weighting factors vary by type of benefit, guarantee duration, and valuation basis (i.e. 'issue year'
basis or 'change-in-fund' basis). An asterisk (*), where shown with the weighting factor in Table
1, indicates that Formula 2 may optionally be used with a given factor if an acceptable actuarial
opinion and memorandum are provided, as required by Section 4217(c)(4)(B)(vi).

TABLE 1

Valuation

Benefit

Guarantee Duration

Basis

(Category in

(Where duration t,

Circular Letter)

in years, is)

A

= or < 10

Issue

> 10, = or < 20

Year

> 20

B

= or < 10

Issue Year

> 10, = or < 20

Issue Year

> 20

Issue Year

B

= or < 10

Change-in-Fund

> 10, = or < 20

Change-in-Fund

> 20

Change-in-Fund

C

Not applicable

Issue or

Purchase Year

(1)

Reference

Weighting

Benefit

Interest Rata

Factor

(Category in

(Column from

Circular Letter)

Table 2)

A

(3)

.50

.45

.35

B

(1)

.55*

(3)

.50

(3)

.40

B

(1)

.60*

(1)

.55*

(1)

.45*

C

.80*

Valuation

Reference

Benefit

Guarantee Duration

Basis

Interest Rate

(Category in

(Where duration t,

(Column from

Circular Letter)

in years, is)

Table 2)

D

= or < 5

Issue

(1)

> 5, = or < 10

Year

(1)

> 10, = or < 20

(3)

> 20

(3)

Issue

E

= or < 5

Year

(1)

> 5, = or <,10

(1)

> 10, = or <20

(3)

> 20

(3)

F

= or < 5,

Issue

(1)

> 5, = or < 10

Year

(l)

> 10, = or < 20

(1)

> 20

(1)

G

= or < 5

Change

(1)

> 5, = or < 10

in

(1)

> 10, = or < 20

Fund

(1)

> 20

(1)

H

= or < 5

Chanae

(1)

> 5, = or < 10

in

(1)

> 10, = or < 20

Fund

(1)

> 20

(1)

Weighting

Benefit

Guarantee Duration

Factor

(Category in

(Where duration t,

Circular Letter)

in years, is)

Varies By Plan Type

A

B

C

D

= or < 5

.80*

.60*

.50*

> 5, = or < 10

.75*

.60*

.50*

> 10, = or < 20

.65

.50

.45

> 20

.45

.35

.35

A

B

C

E

= or < 5

.85*

.65*

.55*

> 5, = or <,10

.80*

.65*

.55*

> 10, = or <20

.70

.55

.50

> 20

.50

.40

.40

A

F

= or < 5,

.80*

> 5, = or < 10

.75*

> 10, = or < 20

.65*

> 20

.45*

A

B

C

G

= or < 5

.95*

.85*

.55*

> 5, = or < 10

.90*

.85*

.55*

> 10, = or < 20

.80*

.75*

.50*

> 20

.60*

.60*

.40*

A

B

C

H

= or < 5

1.00*

.90

.60*

> 5, = or < 10

.95*

.90*

.60*

> 10, = or < 20

.85*

.80*

.55*

> 20

.65*

.65*

.45*

The reference interest rates are based on the average corporate bond earnings published by Moody's
Investors Service, Inc.

Section 4217 defines running averages of the published monthly yield rates for 12-month and 36-month
periods.

The year of issue, of purchase or of change-in-fund, applicable to the running yield average ending
in the current year, is the next following year for Life. Insurance other than single premium life
insurance of the kind referred to in Section 4217(c)(4)(B)(vi) (i.e. Category A in the Circular Letter)
and the current year for all other business (i.e. Categories B through H in the Circular Letter).

The following table shows Moody's yield averages for recent years:

TABLE 2

For Period

Ending

12-Month

36-Month

June 30

Running

Running

Lesser of

of Year

Average

Average

Two Averages

(1)

(2)

(3)

1981

13.71%

11.57%

11.57%

1982

15.70

13.64

13.64

1983

13.39%

14.26%

13.39%

1984

13.22

14.10

13.22

1985

13.01%

13.21%

13.01%

1986

10.75

12.33

10.75

1987

9.40%

11.05%

9.40%

1988

10.32

10.15

10.15

1989

10.09%

9.93%

9.93%

1990

9.52

9.97

9.52

1991

9.63%

9.74%

9.63%

The maximum nonforfeiture interest rate for Life Insurance, under Section 422)(k), for a particular
issue year, is equal to 125% of the maximum reserve valuation interest rate for the same issue year,
rounded to the nearer 1/4%.

Should the computed maximum reserve valuation interest rate for Life Insurance (other than Single
Premium Life Insurance covered in Category B on page 3 of the Circular letter) for a particular issue
year be different from the actual maximum reserve valuation Interest rate for the next previous issue
year by less than 1/2%, then the maximum reserve valuation interest rate for such particular issue
year will be the same as that for such next previous issue year.